Return of criminal assets in the EAEU: a comparative analysis of confiscation mechanisms and prospects for a unified legal approach

the article examines the legal regulation of criminal asset recovery in five member states of the Eurasian Economic Union (EAEU): Armenia, Belarus, Kazakhstan, Kyrgyzstan, and Russia. The aim of the study is to identify differences and common features in the application of asset confiscation mechanisms, as well as to assess the prospects for developing a unified legal approach within the EAEU. The research objectives include the systematization and comparison of national confiscation models, identification of institutional and legal barriers to harmonization, and the development of proposals for unifying procedures for asset seizure, confiscation, and the recognition of foreign court decisions. Special attention is given to issues of civil confiscation, provisional freezing of assets, and the role of digital tools in cross-border legal cooperation. The practical significance of the study lies in the potential application of its findings and recommendations for drafting model legislation, creating a digital platform for mutual legal assistance, and establishing a specialized coordination body for asset recovery within the EAEU. The results are of interest to legislators, law enforcement and judicial authorities, international organizations, and may also be used in legal and anti-corruption education programs.

asset recovery, confiscation of assets, criminal proceeds, international cooperation, Eurasian Economic Union (EAEU), harmonization of legislation